Legal Opinion

Cohen v. Commissioner

United States Tax Court

Decided August 31, 1955No. Docket No. 48725Published

Capital Expenditures or Ordinary and Necessary Expense -- Defense of Title -- Sec. 23 (a). -- Amounts paid for attorneys' fees and litigation expense by the owner of property, a defendant in a suit by a wife claiming that the property belonged to her estranged husband who had transferred it to the taxpayer in fraud of her claim, were capital expenditures not deductible as expenses under section 23 (a).

1Opinion of the Court

Samuel Cohen and Sarah Shechter Cohen, Petitioners, v. Commissioner of Internal Revenue, Respondent

Cohen v. Commissioner

Docket No. 48725

United States Tax Court

24 T.C. 957; 1955 U.S. Tax Ct. LEXIS 106;

August 31, 1955, Filed

Decision will be entered for the respondent.

Capital Expenditures or Ordinary and Necessary Expense -- Defense of Title -- Sec. 23 (a). -- Amounts paid for attorneys' fees and litigation expense by the owner of property, a defendant in a suit by a wife claiming that the property belonged to her estranged husband who had transferred it to the taxpayer in fraud of her claim,…

2Cases cited1 opinion

  1. Cohen v. CommissionerUnited States Tax Court · 1955

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